This Privacy Policy describes how we handle your personal information for our services on our Web site (this "Site"). Our company collects information from all end users of our services (the "Products" and/or "Services"), those who access some of our Services but do not have accounts ("Visitors"), as well as those who may purchase Products and/or Services ("Members"). We request that you read this Privacy Policy carefully.

Personal Information Our Company Collects and How It Is Used

Introduction: Our company collects information in different ways from Visitors and Members who access the various parts of our Services and the network of Web sites accessible through our Services.

Registration: Members may be asked to provide certain personal information when they sign up for our Products or Services, including name, address, telephone number, billing information (such as a credit card number), and the type of personal computer being used to access the Services. The personal information collected from Members during the registration process is used to manage each Member's account (such as for billing purposes). This information may be shared with third parties, as stated herein, or in special circumstances.

However, in instances where our company and a partner jointly promote our Services, we may provide the partner certain personal information, such as the name, address, and user name of persons who subscribe to the Services as a result of the joint promotion, for the purpose of offering you other products and services.

In this instance, personal information may not be used by the partner for any other purpose. We may also generate non-identifying and aggregate profiles from personal information Members provide during registration (such as the total number, but not the names, of Members). As explained in more detail below, we may use this aggregated and non-identifying information to sell advertisements that appear on the Services.

Also, with purchases, we supply our Member's contact information to our business partners, who then may contact the Member by telephone after the purchase. Sales proceeds are collected by the business partners company. We also may supply other companies with contact information, for mail offers we believe would be of interest to our Members, with or without compensation from those companies. At times, we may send an advertisement for a third-party product, where we collect the sales proceeds, and forward the purchaser's information to that third party.

We use the “Custom Audience pixel” of Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”) on our website. With its help, we can keep track of what users do after they see or click on a Facebook advertisement. This enables us to monitor the effectiveness of Facebook ads for purposes of statistics and market research. Data collected in this way is anonymous to us, which means we cannot see the personal data of individual users. However, this data is saved and processed by Facebook. Facebook can connect this data with your Facebook account and use it for its own advertising purposes, in accordance with Facebook’s Data Policy which can be found at https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on and outside of Facebook. A cookie can also be saved on your device for these purposes.

Our website uses Google Analytics, a web analysis service of Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, www.google.com (“Google Analytics” or “Google”). Google Analytics employs cookies that are stored to your computer in order to facilitate an analysis of your use of the site. The information generated by these cookies, such as time, place and frequency of your visits to our site, including your IP address, is transmitted to Google’s location in the US and stored there.

Google may also transfer this information to third parties where required to do so by law or where such third parties process this data on Google’s behalf. Google states that it will in never associate your IP address with other data held by Google. You can prevent cookies from being installed by adjusting the settings on your browser software accordingly as noted elsewhere in this Privacy Policy. You should be aware, however, that by doing so you may not be able to make full use of all the functions of our website.

Google Analytics also offers a deactivation add-on for most current browsers that provides you with more control over what data Google can collect on websites you access. The add-on tells the JavaScript (ga.js) used by Google Analytics not to transmit any information about website visits to Google Analytics. However, the browser deactivation add-on offered by Google Analytics does not prevent information from being transmitted to us or to other web analysis services we may engage.

Google Analytics also uses electronic images known as web beacons (sometimes called single pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our site is used.

You can find additional information on how to install the browser add-on referenced above at the following link: https://tools.google.com/dlpage/gaoptout?hl=en

Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third-party to recognize you and make your next visit easier and the Service more useful to you.

Cookies can be "persistent" or "session" cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser.

When you use and access our website, we may place a number of cookies files in your web browser.

We use cookies for the following purposes:

Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.

For the Chrome web browser, please visit this page from Google: https://support.google.com/accounts/answer/32050

For the Internet Explorer web browser, please visit this page from Microsoft: http://support.microsoft.com/kb/278835

For the Firefox web browser, please visit this page from Mozilla: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored

For the Safari web browser, please visit this page from Apple: https://support.apple.com/kb/PH21411?locale=en_US

For any other web browser, please visit your web browser's official web pages.

Google Tag Manager (GTM”) is a tag management system to manage JavaScript and HTML tags used for tracking and analytics on websites. Tags are small code elements that, among other things, are used to measure traffic and visitor behaviour: to understand the effect of online advertising and social channels; to set up remarketing and orientation towards target groups; and to test and optimize websites. GTM makes it easier for us to integrate and manage our tags. We use GTM on our website to include the following tracking services:

● Google Analytics

If you have performed deactivation, GTM takes this deactivation into account. For more information about GTM’s privacy practices can be found at https://policies.google.com/privacy?hl=en and terms of use at https://www.google.com/analytics/tag-manager/use-policy/.

Consent to Automated Phone Calls

BY CLICKING THE ACCEPT BUTTON TO THIS PRIVACY POLICY, YOU HEREBY CONSENT THAT WE MAY PLACE AUTOMATED AND/OR LIVE PHONE CALLS TO THE NUMBER YOU PROVIDE AS WELL AS TEXT MESSAGE COMMUNICATION. FOR MORE INFORMATION, CONTACT help@breakthroughX.com.

Our Company Partners and Sponsors: Some products and services may be offered to Visitors and Members in conjunction with an affiliate, independent contractor, seller, or non-affiliated partner. To provide Visitors and Members some of these products and services, the partner may need to collect and maintain personal information.

Online Shopping: At some Web sites, you can purchase products and services or register to receive materials, such as a newsletter, catalog, or new product and service updates. In many cases, you may be asked to provide contact information, such as your name, address, e-mail address, phone number, and credit/debit card information.

If you complete an order for someone else, such as an online gift order sent directly to a recipient, you may be asked to provide information about the recipient, such as the recipient's name, address, and phone number. Our company has no control over the third party’s use of any personal information you provide when placing such an order. Please exercise care when doing so. If you order Services or Products directly from our company, we use the personal information you provide to process that order. We do at times share this information with outside parties that we do business with.

Online Advertisements: Our Company may display our online advertisements. In those cases, we share information about our Visitors and Members collected through the registration process as well as through online surveys and promotions with these advertisers.

Additionally, in some instances, we use this information to deliver tailored advertisements or joint ventures. For instance, an advertiser or joint venture company tells us the audience it wants to reach and provides us an advertisement tailored to the audience. Based upon the information we have collected, we may then display or send the advertisement to the intended audience. Our company does share personal information about its Visitors or Members with these advertisers or joint venture companies.

Responses to E-mail Inquiries: When Visitors or Members send e-mail inquiries to our company, the return e-mail address is used to answer the e-mail inquiry we receive.

Responses to E-mail Inquiries: When Visitors or Members send e-mail inquiries to our company, the return e-mail address is used to answer the e-mail inquiry we receive.

Voluntary Customer Surveys: We may periodically conduct both business and individual customer surveys. We encourage our customers to participate in these surveys because they provide us with important information that helps us to improve the types of Products and Services we offer and how we provide them to you.

We may take the information we receive from individuals responding to our customer surveys and combine (or aggregate) it with the responses of other customers we may have to create broader, generic responses to the survey questions (such as gender, age, residence, hobbies, education, employment, industry sector, or other demographic information). We then use the aggregated information to improve the quality of our Services to you, and to develop new services and products. This aggregated, non-personally identifying information may be shared with third parties.

Promotions: Our Company may offer polls, contests, sweepstakes, drawings, games, content, or other promotions that are sponsored by or co-branded with third parties. You may be entered in a sweepstakes, contest, or other promotion simply by making a purchase from us or by providing us with personally identifiable information for some other reason or purpose. Due to these third-party relationships, the third parties may obtain personally identifiable information that Visitors voluntarily submit to our company. Our company has no control over third parties' use of this information.

Additionally, personally identifiable information may be collected when you order Products, enter contests, vote in polls or otherwise express an opinion, subscribe to one of our Services such as our online newsletters, or participate in one of our online forums or communities. The types of personally identifiable information that may be collected at these pages include, but may not be limited to, name, address, e-mail address, telephone number, fax number, credit card information, and information about your interests in and use of various Products, programs, and Services. Our sponsors or third parties may send you material that relates to our company's Services, Products, or activities.

Special Cases: It is our company's policy to use or share the personal information about Visitors or Members in ways described herein without additional notice or means to opt out or otherwise prohibit such unrelated uses.

Also, we may disclose personal information about Visitors or Members, or information regarding your use of the Services or Web sites accessible through our Services, for any reason if, in our sole discretion, we believe that it is reasonable to do so, including credit agencies, collection agencies, merchant database agencies, law enforcement, or to satisfy laws such as the Electronic Communications Privacy Act, the Child Online Privacy Act, regulations, or governmental or legal requests for such information; to disclose information that is necessary to identify, contact, or bring legal action against someone who may be violating our Acceptable Use Policy or Terms Of Service, or other user policies; to operate the Services properly; or to protect our company and our Members.

Notice of Compliance to California Residents.

This Privacy Policy identifies the categories of personally identifiable information that our company collects through our Web site or online service about individual consumers who use or visit our company's commercial Web site or online service and the categories of third-party persons or entities with whom our company may share that personally identifiable information.

Our company does not maintain a process for an individual consumer who uses or visits our commercial Web site or online service to review and request changes to any of his or her personally identifiable information that is collected through our Web site or online service.

See the section below entitled "Revisions to This Policy" for a description of the process by which our company notifies consumers who use or visit our commercial Web site or online service of material changes to our company's Privacy Policy for this Web site or online service.

The effective date of this Privacy Policy is listed at the end of this Privacy Policy under the heading "Last updated."

For the purposes of this policy and California compliance, the following definitions apply:

Depending on the Visitor's activity in our commercial Web site or online service, the following "personally identifiable information" may be collected in addition to information set forth in other sections of this document.

The term "personally identifiable information" means individually identifiable information about an individual consumer collected online by our company from an individual and maintained

by our company in an accessible form, and may include any of the following:

(1) A first and last name.

(2) A home or other physical address, including street name and name of a city or town.

(3) An e-mail address.

(4) A telephone number.

(5) Any other identifier that permits the physical or online contacting of a specific individual.

(6) Information concerning a user that the Web site or online service collects online from the user and maintains in personally identifiable form in combination with an identifier described within this Privacy Policy.

Under California Law SB 27, California residents have the right to receive, once a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared. To make such a request,

please send an e-mail to help@breakthroughX.com and please include the phrase:

"California Privacy Request" in the subject line, the domain name of the Web site you are inquiring about, along with your name, address, and e-mail address. We will respond to you within thirty business days of receiving such a request.

"Cookies" and How Our Company Uses Them. A "cookie" is a small data file that can be placed on your hard drive when you visit certain Web sites. Our company may use cookies to collect, store, and sometimes track information for purposes stated herein as well as for statistical purposes to improve the Products and Services we provide and to manage our telecommunications networks. 

Advertisers and partners may also use their own cookies. We do not control use of these cookies and expressly disclaim responsibility for information collected through them.

Our Company Commitment to Children's Privacy: Protecting children's privacy is especially important to us. It is our policy to comply with the Children's Online Privacy Protection Act of 1998 and all other applicable laws. Therefore, we restrict our Web site to persons eighteen years or older.

YOU MUST BE EIGHTEEN (18) YEARS OR OLDER TO ACCESS THIS WEB SITE. IF YOU ARE UNDER EIGHTEEN (18) YEARS OF AGE, YOU ARE NOT PERMITTED TO ACCESS THIS WEB SITE FOR ANY REASON. DUE TO THE AGE RESTRICTIONS FOR USE OF THIS WEB SITE, NO INFORMATION OBTAINED BY THIS WEB SITE FALLS WITHIN THE CHILDREN'S ONLINE PRIVACY PROTECTION ACT ("COPPA") AND IS NOT MONITORED AS DOING SO.

Public Forums: Please remember that any information you may disclose in any Member Directory, or other public areas of our Web sites or the Internet, becomes public information. You should exercise caution when deciding to disclose personal information in these public areas.

Our Company's Commitment to Data Security: Services and Web sites we sponsor have security measures in place to protect the loss, misuse, and alteration of the information under our control. While we make every effort to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party "hackers" from illegally obtaining this information.

Where to Direct Questions about Our Privacy Policy: If you have any questions about this Privacy Policy or the practices described herein, you may contact us through the contact information provided on this Web site.

Revisions to this Policy: Our Company reserves the right to revise, amend, or modify this policy, our Terms of Service agreement, and our other policies and agreements at any time and in any manner by updating this posting. Your use of this Site after such changes are implemented constitutes your acknowledgement and acceptance of these changes. Please consult this privacy statement prior to every use for any changes.

Last modified: July 1st, 2017